Privacy Notice and Data Protection Policy

Ann Richards Payroll Services Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of all of our clients and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Information About Us

Ann Richards Payroll Services Limited

A limited company registered in England under company number 04013667

Registered and trading address: 8-9 Borough Court, Grammar School Lane, Halesowen, West Midlands, B63 3SW

VAT number: GB 754 1933 23

Data Protection Officer: Lorraine Southern

Email address: lorraine@aras.co.uk

Telephone number: 0121 550 2500

What Does This Notice Cover?

This Privacy Information explains how we use your personal data: how it is collected, how it is held, and how it is processed. It also explains your rights under the law relating to your personal data.

What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

The personal data that we use is set out in Part 5, below.

What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

a) The right to be informed about our collection and use of your personal data. This Privacy Notice should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 11.

b) The right to access the personal data we hold about you. Part 10 will tell you how to do this.

c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 11 to find out more.

d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 11 to find out more.

e) The right to restrict (i.e. prevent) the processing of your personal data.

f) The right to object to us using your personal data for a particular purpose or purposes.

g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.

h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.

i) Rights relating to automated decision-making and profiling. we do not use your personal data in this way.

For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 11.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 11.

What Personal Data Do We Collect and How?

We may collect and hold some or all of the personal data set out in the table below, using the methods also set out in the table. We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children or data relating to criminal convictions and/or offences.

How We Collect the Data - Directly From You

What Data Do We Collect

Identity Data

Includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data

Includes company address, email address and telephone numbers.

Transaction Data

Includes details about payments to and from you and other details of the services you use from us.

Technical Data

Includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data

Includes your username and password, preferences, feedback and survey responses.

Usage Data

Includes information about how you use our website, products and services.

How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how will/may use your personal data, and our lawful bases for doing so:

What We Do Our Lawful Basis

Administering our business For our legitimate interests or those of a third party

Supplying our services to you To comply with our legal and regulatory obligations

Managing payments for our services For our legitimate interests or those of a third party

Personalising and tailoring services for you For the performance our of services to you

Communicating with you For the performance our of services to you.

Conducting checks to identify our clients and verify their To comply with our legal and regulatory obligations

identity

Gathering and providing information required for To comply with our legal and regulatory obligations.

enquiries or investigations by regulatory bodies.

Ensuring business policies are adhered to, ie policies covering For our legitimate interests or those of a third party

internet use and security

Operational reasons, such as improving efficiency, training For our legitimate interests or those of a third party

and quality control

Ensuring the confidentiality of commercially sensitive To comply with our legal and regulatory obligations

information     For our legitimate interests or those of a third party

Preventing unauthorised access and modifications to systems To comply with our legal and regulatory obligations

  For our legitimate interests or those of a third party

Updating and enhancing client records For the performance our of services to you

  To comply with our legal and regulatory obligations

  For our legitimate interests or those of a third party

Statutory returns To comply with our legal and regulatory obligations

Ensuring safe working practices, staff administration To comply with our legal and regulatory obligations

and assessments For our legitimate interests or those of a third party

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone with information, news. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 11.

If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected, including for the purposes of satisfying any legal, accounting or reporting requirements.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data.

Once you are no longer a client of the company we will retain and securely destroy your personal information in accordance with our privacy standard.

How and Where Do You Store or Transfer My Personal Data?

We will only store your personal data in the UK. This means that it will be fully protected under the Data Protection Legislation.

We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.

The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:

·      limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;

·      procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so;

Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 8.

How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 11. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within less than one month and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details (for the attention of Lorraine Southern:

Email address: lorraine@aras.co.uk

Telephone number: 0121 550 2500

Postal Address: 8-9 Borough Court, Grammar School Lane, Halesowen, West Midlands, B63 3SW

Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

This Privacy Notice was last updated on 1st November 2025.

Introduction

This Policy sets out the obligations of Ann Richards Payroll Services Limited, a company registered in United Kingdom under number 04013667, whose registered office is at 8-9 Borough Court, Grammar School Lane, Halesowen, West Midlands, B63 3SW (“the Company”) regarding data protection and the rights of staff, clients and business contacts (“data subjects”) in respect of their personal data under Data Protection Law. “Data Protection Law” means all applicable legislation in force from time to time in the United Kingdom applicable to data protection and privacy including, but not limited to, the UK GDPR, the Data Protection Act 2018 (and regulations made thereunder), and the Privacy and Electronic Communications Regulations 2003 as amended, and any successor legislation.

This Policy sets out the Company’s obligations regarding the collection, processing, transfer, storage, and disposal of personal data. The procedures and principles set out herein must be followed at all times by the Company, its employees, agents, contractors, or other parties working on behalf of the Company.

Definitions

 “consent” - means the consent of the data subject which must be a freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify their agreement to the processing of personal data relating to them;

“data controller” - means the natural or legal person or organisation which, alone or jointly with others, determines the purposes and means of the processing of personal data. For the purposes of this Policy, the Company is the data controller of all personal data relating to staff, Clients and business contacts used in our business for our commercial purposes;

“data processor” - means a natural or legal person or organisation which processes personal data on behalf of a data controller;

“data subject” - means a living, identified, or identifiable natural person about whom the Company holds personal data;

“EEA” - means the European Economic Area, consisting of all EU Member States, Iceland, Liechtenstein, and Norway;

“personal data” - means any information relating to a data subject who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that data subject;

“personal data breach” - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed;

“processing” - means any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“pseudonymisation” - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data is not attributed to an identified or identifiable natural person; and

“special category personal data” - means personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, sexual life, sexual orientation, biometric, or genetic data.

Scope

The Company is committed not only to the letter of the law, but also to the spirit of the law and places high importance on the correct, lawful, and fair handling of all personal data, respecting the legal rights, privacy, and trust of all individuals with whom it deals.

The Company’s Data Protection Officer is Lorraine Southern, lorraine@aras.co.uk. The Data Protection Officer is responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

All managers and supervisors are responsible for ensuring that all employees, agents, contractors, or other parties working on behalf of the Company comply with this Policy and, where applicable, must implement such practices, processes, controls, and training as are reasonably necessary to ensure such compliance.

 Any questions relating to this Policy or to Data Protection Law should be referred to the Data Protection Officer. In particular, the Data Protection Officer should always be consulted in the following cases:

a)            if there is any uncertainty relating to the lawful basis on which personal data is to be collected, held,         and/or processed;

b)            if consent is being relied upon in order to collect, hold, and/or process personal data;

c)            if there is any uncertainty relating to the retention period for any particular type(s) of personal data;

d)            if any new or amended privacy notices or similar privacy-related documentation are required;

e)            if any assistance is required in dealing with the exercise of a data subject’s rights (including, but not           limited to, the handling of subject access requests);

f)             if a personal data breach (suspected or actual) has occurred;

g)            if there is any uncertainty relating to security measures (whether technical or organisational)           required to protect personal data;

h)            if personal data is to be shared with third parties (whether such third parties are acting as data             controllers or data processors);

i)             if personal data is to be transferred outside of the UK and there are questions relating to the legal         basis on which to do so;

j)             when any significant new processing activity is to be carried out, or significant changes are to be             made to existing processing activities, which will require a Data Protection Impact Assessment;

k)            when personal data is to be used for purposes different to those for which it was originally collected;

l)             if any automated processing, including profiling or automated decision-making, is to be carried out;         or

m)          if any assistance is required in complying with the law applicable to direct marketing.

 The Data Protection Principles

This Policy aims to ensure compliance with Data Protection Law. The UK GDPR sets out the following principles with which any party handling personal data must comply. Data controllers are responsible for, and must be able to demonstrate, such compliance. All personal data must be:

processed lawfully, fairly, and in a transparent manner in relation to the data subject;

    collected for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes.

Further processing for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes shall not be considered to be incompatible with the initial purposes;

adequate, relevant, and limited to what is necessary in relation to the purposes for which it is processed;

accurate and, where necessary, kept up to date. Every reasonable step must be taken to ensure that personal data that is inaccurate, having regard to the purposes for which it is processed, is erased, or rectified without delay;

kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data is processed. Personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes, subject to implementation of the appropriate technical and organisational measures required by the UK GDPR in order to safeguard the rights and freedoms of the data subject;

processed in a manner that ensures appropriate security of the personal data, including protection against               unauthorised or unlawful processing and against accidental loss, destruction, or damage, using appropriate             technical or organisational measures.

The Rights of Data Subjects

The UK GDPR sets out the following key rights applicable to data subjects:

the right to be informed;

the right of access;

the right to rectification;

the right to erasure (also known as the ‘right to be forgotten’);

the right to restrict processing;

the right to data portability;

the right to object;

rights with respect to automated decision-making and profiling

Lawful, Fair, and Transparent Data Processing

Data Protection Law seeks to ensure that personal data is processed lawfully, fairly, and transparently, without adversely affecting the rights of the data subject. Specifically, the processing of personal data shall be lawful if at least one of the following applies:

a)            the data subject has given consent to the processing of their personal data for one or more specific purposes;

b)            the processing is necessary for the performance of a contract to which the data subject is a party, or in order to take         steps at the request of the data subject prior to entering into a contract;

c)            the processing is necessary for compliance with a legal obligation to which the data controller is subject;

d)            the processing is necessary to protect the vital interests of the data subject or of another natural person;

e)            the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official         authority vested in the data controller; or

f)             the processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third         party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Consent

If consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, the following shall apply:

Consent is a clear indication by the data subject that they agree to the processing of their personal data. Such a clear indication may take the form of a statement or a positive action. Silence, pre-ticked boxes, or inactivity are unlikely to amount to consent.

Where consent is given in a document which includes other matters, the section dealing with consent must be kept clearly separate from such other matters.

Data subjects are free to withdraw consent at any time and it must be made easy for them to do so. If a data subject withdraws consent, their request must be honoured promptly.

If personal data is to be processed for a different purpose that is incompatible with the purpose or purposes for which that personal data was originally collected that was not disclosed to the data subject when they first provided their consent, consent to the new purpose or purposes may need to be obtained from the data subject.

In all cases where consent is relied upon as the lawful basis for collecting, holding, and/or processing personal data, records must be kept of all consents obtained in order to ensure that the Company can demonstrate its compliance with consent requirements.

Specified, Explicit, and Legitimate Purposes

The Company collects and processes the personal data set out in Part 22 of this Policy. This includes:

a)            personal data collected directly from data subjects.

b)            personal data obtained from third parties.

The Company only collects, processes, and holds personal data for the specific purposes set out in Part 22 of this Policy (or for other purposes expressly permitted by Data Protection Law).

Data subjects must be kept informed at all times of the purpose or purposes for which the Company uses their personal data. Please refer to Part 15 for more information on keeping data subjects informed.

Adequate, Relevant, and Limited Data Processing

The Company will only collect and process personal data for and to the extent necessary for the specific purpose or purposes of which data subjects have been informed (or will be informed) as under Part 8, above, and as set out in Part 22, below.

Employees, agents, contractors, or other parties working on behalf of the Company may collect personal data only to the extent required for the performance of their job duties and only in accordance with this Policy. Excessive personal data must not be collected.

Employees, agents, contractors, or other parties working on behalf of the Company may process personal data only when the performance of their job duties requires it. Personal data held by the Company cannot be processed for any unrelated reasons.

Accuracy of Data and Keeping Data Up-to-Date

The Company shall ensure that all personal data collected, processed, and held by it is kept accurate and up-to-date. This includes, but is not limited to, the rectification of personal data at the request of a data subject, as set out in Part 17, below.

The accuracy of personal data shall be checked when it is collected and at regular intervals thereafter. If any personal data is found to be inaccurate or out-of-date, all reasonable steps will be taken without delay to amend or erase that data, as appropriate.

Data Retention

The Company shall not keep personal data for any longer than is necessary in light of the purpose or purposes for which that personal data was originally collected, held, and processed.

When personal data is no longer required, all reasonable steps will be taken to erase or otherwise dispose of it without delay.

For full details of the Company’s approach to data retention, including retention periods for specific personal data types held by the Company, please refer to our Data Retention Policy.

Secure Processing

The Company shall ensure that all personal data collected, held, and processed is kept secure and protected against unauthorised or unlawful processing and against accidental loss, destruction, or damage. Further details of the technical and organisational measures which shall be taken are provided in Parts 25 to 30 of this Policy.

All technical and organisational measures taken to protect personal data shall be regularly reviewed and evaluated to ensure their ongoing effectiveness and the continued security of personal data.

Data security must be maintained at all times by protecting the confidentiality, integrity, and availability of all personal data as follows:

a)            only those with a genuine need to access and use personal data and who are authorised to do so may access and use it;

b)            personal data must be accurate and suitable for the purpose or purposes for which it is collected, held, and processed; and

c)            authorised users must always be able to access the personal data as required for the authorised purpose or purposes.

Accountability and Record-Keeping

The Data Protection Officer is responsible for administering this Policy and for developing and implementing any applicable related policies, procedures, and/or guidelines.

The Company shall follow a privacy by design approach at all times when collecting, holding, and processing personal data. Data Protection Impact Assessments shall be conducted if any processing presents a significant risk to the rights and freedoms of data subjects (please refer to Part 14 for further information).

All employees, agents, contractors, or other parties working on behalf of the Company shall be given appropriate training in data protection and privacy, addressing the relevant aspects of Data Protection Law, this Policy, and all other applicable Company policies.

The Company’s data protection compliance shall be regularly reviewed and evaluated by means of Data Protection Audits.

The Company shall keep written internal records of all personal data collection, holding, and processing, which shall incorporate the following information:

a)            the name and details of the Company, its Data Protection Officer, and any applicable third-party data transfers         (including data processors and other data controllers with whom personal data is shared);

b)            the purposes for which the Company collects, holds, and processes personal data;

c)            the Company’s legal basis or bases (including, but not limited to, consent, the mechanism(s) for obtaining such       consent, and records of such consent) for collecting, holding, and processing personal data;

d)            details of the categories of personal data collected, held, and processed by the Company, and the categories of data subject to which that personal data relates;

e)            details of any transfers of personal data to non-UK countries including all mechanisms and security safeguards;

f)             details of how long personal data will be retained by the Company (please refer to the Company’s Data Retention Policy);

g)            details of personal data storage, including location(s);

h)            detailed descriptions of all technical and organisational measures taken by the Company to ensure the security of         personal data.

Data Protection Impact Assessments and Privacy by Design

In accordance with the privacy by design principles, the Company shall carry out Data Protection Impact Assessments for any and all new projects and/or new uses of personal data which involve the use of new technologies and where the processing involved is likely to result in a high risk to the rights and freedoms of data subjects.

The principles of privacy by design should be followed at all times when collecting, holding, and processing personal data. The following factors should be taken into consideration:

a)            the nature, scope, context, and purpose or purposes of the collection, holding, and processing;

b)            the state of the art of all relevant technical and organisational measures to be taken;

c)            the cost of implementing such measures; and

d)            the risks posed to data subjects and to the Company, including their likelihood and severity.

Data Protection Impact Assessments shall be overseen by the Data Protection Officer and shall address the following:

a)            the type(s) of personal data that will be collected, held, and processed;

b)            the purpose(s) for which personal data is to be used;

c)            the Company’s objectives;

d)            how personal data is to be used;

e)            the parties (internal and/or external) who are to be consulted;

f)             the necessity and proportionality of the data processing with respect to the purpose(s) for which it is being processed;

g)            risks posed to data subjects;

h)            risks posed both within and to the Company; and

i)             proposed measures to minimise and handle identified risks.

Keeping Data Subjects Informed

The Company shall provide the information set out in Part 15.2 to every data subject:

a)            where personal data is collected directly from data subjects, those data subjects will be informed of its purpose at the time of collection;

and

b)            where personal data is obtained from a third party, the relevant data subjects will be informed of its purpose:

i)             if the personal data is used to communicate with the data subject, when the first communication is made; or

ii)            if the personal data is to be transferred to another party, before that transfer is made; or

   iii)          as soon as reasonably possible and in any event not more than one month after the personal data is obtained.

The following information shall be provided in the form of a privacy notice:

a)            details of the Company including, but not limited to, contact details, and the names and contact details of any           applicable representatives and its Data Protection Officer;

b)            the purpose(s) for which the personal data is being collected and will be processed (as detailed in Part 22 of this Policy) and the lawful basis justifying that collection and processing;

c)            where applicable, the legitimate interests upon which the Company is justifying its collection and processing of the         personal data;

d)            where the personal data is not obtained directly from the data subject, the categories of personal data collected and processed;

e)            where the personal data is to be transferred to one or more third parties, details of those parties;

f)             where the personal data is to be transferred to a third party that is located outside of the UK, details of that transfer,         including but not limited to the safeguards in place (see Part 31 of this Policy for further details);

g)            details of applicable data retention periods;

h)            details of the data subject’s rights under the UK GDPR;

i)             details of the data subject’s right to withdraw their consent to the Company’s processing of their personal data at any time;

j)             details of the data subject’s right to complain to the Information Commissioner’s Office;

k)            where the personal data is not obtained directly from the data subject, details about the source of that personal data;

l)             where applicable, details of any legal or contractual requirement or obligation necessitating the collection and     processing of the personal data and details of any consequences of failing to provide it; and

m)         details of any automated decision-making or profiling that will take place using the personal data, including     information on how decisions will be made, the significance of those decisions, and any consequences.

Data Subject Access

Data subjects may make subject access requests (“SARs”) at any time to find out more about the personal data which the Company holds about them, what it is doing with that personal data, and why.

Employees wishing to make a SAR should do using a Subject Access Request Form, sending the form to the Company’s Data Protection Officer at lorraine@aras.co.uk.

Responses to SARs must normally be made within one month of receipt, however, this may be extended by up to two months if the SAR is complex and/or numerous requests are made. If such additional time is required, the data subject shall be informed.

All SARs received shall be handled by the Company’s Data Protection Officer and in accordance with the Company’s Data Subject Access Request Policy & Procedure.

The Company does not charge a fee for the handling of normal SARs. The Company reserves the right to charge reasonable fees for additional copies of information that has already been supplied to a data subject, and for requests that are manifestly unfounded or excessive, particularly where such requests are repetitive.

Rectification of Personal Data

Data subjects have the right to require the Company to rectify any of their personal data that is inaccurate or incomplete.

The Company shall rectify the personal data in question, and inform the data subject of that rectification, within one month of the data subject informing the Company of the issue. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of any rectification that must be made to that personal data.

Erasure of Personal Data

Data subjects have the right to request that the Company erases the personal data it holds about them in the following circumstances:

a)            it is no longer necessary for the Company to hold that personal data with respect to the purpose(s) for  which it was         originally collected or processed;

b)            the data subject wishes to withdraw their consent to the Company holding and processing their personal data;

c)            the data subject objects to the Company holding and processing their personal data (and there is no overriding             legitimate interest to allow the Company to continue doing so) (see Part 21 of this Policy for further details concerning         the right to object);

d)            the personal data has been processed unlawfully;

e)            the personal data needs to be erased in order for the Company to comply with a particular legal obligation.

Unless the Company has reasonable grounds to refuse to erase personal data, all requests for erasure shall be complied with, and the data subject informed of the erasure, within one month of receipt of the data subject’s request. The period can be extended by up to two months in the case of complex requests. If such additional time is required, the data subject shall be informed.

In the event that any personal data that is to be erased in response to a data subject’s request has been disclosed to third parties, those parties shall be informed of the erasure (unless it is impossible or would require disproportionate effort to do so).

Restriction of Personal Data Processing

Data subjects may request that the Company ceases processing the personal data it holds about them. If a data subject makes such a request, the Company shall retain only the amount of personal data concerning that data subject (if any) that is necessary to ensure that the personal data in question is not processed further.

In the event that any affected personal data has been disclosed to third parties, those parties shall be informed of the applicable restrictions on processing it (unless it is impossible or would require disproportionate effort to do so).

Objections to Personal Data Processing

Data subjects have the right to object to the Company processing their personal data based on legitimate interests, for direct marketing (including profiling),

Where a data subject objects to the Company processing their personal data based on its legitimate interests, the Company shall cease such processing immediately, unless it can be demonstrated that the Company’s legitimate grounds for such processing override the data subject’s interests, rights, and freedoms, or that the processing is necessary for the conduct of legal claims.

Where a data subject objects to the Company processing their personal data for direct marketing purposes, the Company shall cease such processing promptly.

Direct Marketing

The Company is subject to certain rules and regulations when marketing its services.

The prior consent of data subjects is required for electronic direct marketing including email, text messaging, and automated telephone calls subject to the following limited exception:

a)            The Company may send marketing text messages or emails to a customer provided that that customer’s contact         details have been obtained in the course of a sale, the marketing relates to similar products or services, and the           customer in question has been given the opportunity to opt-out of marketing when their details were first collected         and in every subsequent communication from the Company.

The right to object to direct marketing shall be explicitly offered to data subjects in a clear and intelligible manner and must be kept separate from other information in order to preserve its clarity.

If a data subject objects to direct marketing, their request must be complied with promptly. A limited amount of personal data may be retained in such circumstances to the extent required to ensure that the data subject’s marketing preferences continue to be complied with.

Personal Data Collected, Held, and Processed

The following personal data is collected, held, and processed by the Company (for details of data retention, please refer to the Company’s Data Retention Policy):

  Type of Data Purpose of Data

Name, Title, Addresses, Telephone Numbers     To comply with our legal and regulatory obligations

and Personal Email Addresses

Date of Birth, Gender, Marital Status, Next of Kin     To comply with our legal and regulatory obligations

and Emergency Contact Information and Dependants

National Insurance Number, Bank Account Details,     For the performance our of services to you

Credit Card Statements, Payroll Records and Tax Status

Business documentations     For the performance our of services to you

UTR Number     For the performance our of services to you.

Identity Documents   To comply with our legal and regulatory obligations

Data Security - Transferring Personal Data and Communications

The Company shall ensure that the following measures are taken with respect to all communications and other transfers involving personal data:

All emails containing personal data must be encrypted and set via a safe portal;

All emails containing personal data must be marked “confidential”;

Personal data may be transmitted over secure networks only; transmission over unsecured networks is not permitted in any circumstances;

Personal data may not be transmitted over a wireless network if there is a wired alternative that is reasonably practicable;

Personal data contained in the body of an email, whether sent or received, should be copied from the body of that email and stored securely. The email itself should be deleted. All temporary files associated therewith should also be deleted;

Where personal data is to be sent by facsimile transmission the recipient should be informed in advance of the transmission and should be waiting by the fax machine to receive the data;

Where personal data is to be transferred in hardcopy form it should be passed directly to the recipient via Royal Mail or direct to the client;

All personal data to be transferred physically, whether in hardcopy form or on removable electronic media shall be transferred in a suitable container marked “confidential”;

 Data Security - Storage

The Company shall ensure that the following measures are taken with respect to the storage of personal data:

All electronic copies of personal data should be stored securely using passwords and data encryption;

All hardcopies of personal data, along with any electronic copies stored on physical, removable media should be stored securely in a locked box, drawer, cabinet, or similar;

All personal data stored electronically should be backed up with backups stored onsite and offsite. All backups should be encrypted;

No personal data should be stored on any mobile device (including, but not limited to, laptops, tablets, and smartphones), whether such device belongs to the Company or otherwise;

No personal data should be transferred to any device personally belonging to an employee, agent, contractor, or other party working on behalf of the Company and personal data may only be transferred to devices belonging to agents, contractors, or other parties working on behalf of the Company where the party in question has agreed to comply fully with the letter and spirit of this Policy and of the applicable Data Protection Law (which may include demonstrating to the Company that all suitable technical and organisational measures have been taken);

Data Security - Disposal

When any personal data is to be erased or otherwise disposed of for any reason (including where copies have been made and are no longer needed), it should be securely deleted and disposed of. For further information on the deletion and disposal of personal data, please refer to the Company’s Data Retention Policy.

Data Security - Use of Personal Data

The Company shall ensure that the following measures are taken with respect to the use of personal data:

No personal data may be shared informally and if an employee, agent, contractor, or other party working on behalf of the Company requires access to any personal data that they do not already have access to, such access should be formally requested from client contact or a director of the business;

No personal data may be transferred to any employee, agent, contractor, or other party, whether such parties are working on behalf of the Company or not, without the authorisation of our normal client contact or director of the business;

Personal data must be handled with care at all times and should not be left unattended or on view to unauthorised employees, agents, contractors, or other parties at any time;

If personal data is being viewed on a computer screen and the computer in question is to be left unattended for any period of time, the user must lock the computer and screen before leaving it;

Where personal data held by the Company is used for marketing purposes, it shall be the responsibility of Lorraine Southern to ensure that the appropriate consent is obtained and that no data subjects have opted out, whether directly or via a third-party service such as the TPS;

Data Security - IT Security

The Company shall ensure that the following measures are taken with respect to IT and information security:

All passwords used to protect personal data should be changed regularly and should not use words or phrases that can be easily guessed or otherwise compromised. All passwords must contain a combination of uppercase and lowercase letters, numbers, and symbols. All software used by the Company is designed to require such passwords.;

Under no circumstances should any passwords be written down or shared between any employees, agents, contractors, or other parties working on behalf of the Company, irrespective of seniority or department. If a password is forgotten, it must be reset using the applicable method. IT staff do not have access to passwords;

All software (including, but not limited to, applications and operating systems) shall be kept up-to-date. The Company’s IT staff shall be responsible for installing any and all security-related updates the updates are made available by the publisher or manufacturer or as soon as reasonably and practically possible, unless there are valid technical reasons not to do so;

No software may be installed on any Company-owned computer or device without the prior approval of the IT provider or Lorraine Southern.

Organisational Measures

The Company shall ensure that the following measures are taken with respect to the collection, holding, and processing of personal data:

All employees, agents, contractors, or other parties working on behalf of the Company shall be made fully aware of both their individual responsibilities and the Company’s responsibilities under Data Protection Law and under this Policy, and shall be provided with a copy of this Policy;

Only employees, agents, contractors, or other parties working on behalf of the Company that need access to, and use of, personal data in order to carry out their assigned duties correctly shall have access to personal data held by the Company;

All sharing of personal data shall comply with the information provided to the relevant data subjects and, if required, the consent of such data subjects shall be obtained prior to the sharing of their personal data;

All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately trained to do so;

All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be appropriately supervised;

All employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be required and encouraged to exercise care, caution, and discretion when discussing work-related matters that relate to personal data, whether in the workplace or otherwise;

Methods of collecting, holding, and processing personal data shall be regularly evaluated and reviewed;

All personal data held by the Company shall be reviewed periodically, as set out in the Company’s Data Retention Policy;

The performance of those employees, agents, contractors, or other parties working on behalf of the Company handling personal data shall be regularly evaluated and reviewed;

All employees, agents, contractors, or other parties working on behalf of the Company handling personal data will be bound to do so in accordance with the principles of Data Protection Law and this Policy by contract;

All agents, contractors, or other parties working on behalf of the Company handling personal data must ensure that any and all of their employees who are involved in the processing of personal data are held to the same conditions as those relevant employees of the Company arising out of this Policy and Data Protection Law;

Where any agent, contractor or other party working on behalf of the Company handling personal data fails in their obligations under this Policy that party shall indemnify and hold harmless the Company against any costs, liability, damages, loss, claims or proceedings which may arise out of that failure;

Data Breach Notification

All personal data breaches must be reported immediately to the Company’s Data Protection Officer.

If an employee, agent, contractor, or other party working on behalf of the Company becomes aware of or suspects that a personal data breach has occurred, they must not attempt to investigate it themselves. Any and all evidence relating to the personal data breach in question should be carefully retained.

If a personal data breach occurs and that breach is likely to result in a risk to the rights and freedoms of data subjects (e.g. financial loss, breach of confidentiality, discrimination, reputational damage, or other significant social or economic damage), the Data Protection Officer must ensure that the Information Commissioner’s Office is informed of the breach without delay, and in any event, within 72 hours after having become aware of it.

In the event that a personal data breach is likely to result in a high risk (that is, a higher risk than that described under Part 32.3) to the rights and freedoms of data subjects, the Data Protection Officer must ensure that all affected data subjects are informed of the breach directly and without undue delay.

Data breach notifications shall include the following information:

a)            The categories and approximate number of data subjects concerned;

b)            The categories and approximate number of personal data records concerned;

c)            The name and contact details of the Company’s data protection officer (or other contact point where more             information can be obtained);

d)            The likely consequences of the breach;

e)            Details of the measures taken, or proposed to be taken, by the Company to address the breach including, where         appropriate, measures to mitigate its possible adverse effects.

Implementation of Policy

This Policy shall be deemed effective as of 1st November 2025. No part of this Policy shall have retroactive effect and shall thus apply only to matters occurring on or after this date.

This Policy has been approved and authorised by:

Name : Lorraine Southern

Position : Managing Director

Date : 7th October 2025